Regulatory Compliance & Agency Engagement

  • May 7, 2021
    Joint Financial Trades Statement on Federal Reserve’s Decision to Revisit Reg II WASHINGTON – The Consumer Bankers Association today released the following statement with the American Bankers Association, Bank Policy Institute, Credit Union National Association and National Association of Federally-Insured Credit Unions after the Federal Reserve announced its decision to consider changes to...
  • April 15, 2021
    CBA Calls for Continued Efforts to Level Playing Field, Highlights Dangers of ILC Charters Without Adequate Supervision WASHINGTON – In advance of the House Subcommittee on Consumer Protection and Financial Institutions hearing today entitled “Banking Innovation or Regulatory Evasion? Exploring Trends in Financial Institution Charters,” the Consumer Bankers Association wrote a letter to...
  • February 23, 2021
    CBA Statement on FDIC Quarterly Banking Profile WASHINGTON – Consumer Bankers Association President and CEO Richard Hunt issued the following statement after the Federal Deposit Insurance Corporation released its full-year and fourth quarter 2020 performance report: “The FDIC’s latest report reveals the nation’s banks remained strong and resilient throughout 2020 despite the financial impact of...
  • December 22, 2020
    To Whom It May Concern: The Consumer Bankers Association (CBA) is pleased to submit these comments to the Bureau of Consumer Financial Protection, Office of the Comptroller of the Currency, Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, and National Credit Union Administration (together, the “Agencies”) in response to the Notice of Proposed Rulemaking (...
  • December 1, 2020
    CBA Statement on FDIC Quarterly Banking Profile WASHINGTON – Consumer Bankers Association President and CEO Richard Hunt issued the following statement on the Federal Deposit Insurance Corporation’s quarterly banking profile: “The FDIC’s third quarter report revealed strong capital levels and historically low problem bank numbers, a testament to the industry’s efforts to build a solid, resilient...
  • October 29, 2020
    On Thursday, October 29, 2020, the five federal financial regulatory agencies issued a press release inviting comment on a proposal outlining and confirming the agencies’ use of supervisory guidance for regulated institutions. The proposal would codify the statement, as amended, that was issued in September 2018 by the agencies that clarified the differences between regulations and guidance...
  • October 29, 2020
    On Thursday, October 29, 2020, the Bureau issued a final rule amending its Disclosure of Records and Information Regulation. The rule seeks to balance concerns regarding the Bureau’s need to protect confidential personal, business, supervisory, and investigative information against the need to use and disclose certain information in the course of the Bureau’s work or the work of other agencies...
  • October 27, 2020
    On Tuesday, October 27, 2020, the OCC issued a press release regarding a rule that determines when a national bank or federal savings association (bank) makes a loan and is the “true lender,” including in the context of a partnership between a bank and a third party. Banks’ lending relationships with third parties can facilitate access to affordable credit. However, increasing legal uncertainty...
  • October 20, 2020
    On Tuesday, October 20, 2020, the OCC, Federal Reserve Board, FDIC, NCUA, and CFPB (collectively, the agencies) issued a press release inviting comment on a proposed rule that would codify the Interagency Statement Clarifying the Role of Supervisory Guidance issued by the agencies on September 11, 2018; the so-called “guidance on guidance” document. The proposed rule codifies the 2018 Statement...
  • October 20, 2020
    Dear Mr. Feldman: The Consumer Bankers Association (“CBA”) appreciates the opportunity to respond to the Federal Deposit Insurance Corporation’s (“the FDIC” or “the Agency”) notice and request for comment (“the Proposal”) regarding revisions to the agency’s Guidelines for Appeals of Material Supervisory Determinations (“Guidelines”). We applaud the FDIC’s efforts to enhance the independence of...

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